NickP05

PLYNX - PRIVACY POLICY

Last updated: November 26, 2025

This Privacy Policy (“Policy”) describes how Plynx (“Plynx”, “we”, “us”, or “our”) collects, uses, discloses, and protects your information when you use the Plynx mobile application (“App”) and related services (collectively, the “Services”).

We are committed to protecting your privacy and handling your data with transparency. Please read this Policy carefully.

SUMMARY

In brief:

We collect minimal personal data: email address and password hash for authentication
We collect technical data: IP addresses, device tokens, widget/dashboard configurations
We do NOT collect your name, phone number, physical address, or payment information (unless you provide it)
We do NOT sell your data to third parties
We do NOT use third-party analytics in the App (only App Store standard statistics)
We do NOT share your data for marketing purposes
You can request deletion of your data at any time

Who We Are
What Information We Collect
How We Use Your Information
How We Store Your Information
How We Share Your Information
Data Retention
Your Rights and Choices
Data Security
International Data Transfers
Children’s Privacy
Third-Party Links and Services
California Privacy Rights (CCPA)
European Privacy Rights (GDPR)
Changes to This Policy
Contact Us

1. WHO WE ARE

Plynx is developed and operated by:

Niccolo Pagano (NickP005)
Email: niccolo.pagano@studbocconi.it
Website: https://plynx.cc

For GDPR purposes, Niccolo Pagano is the Data Controller for personal data collected through the Plynx Cloud Server (plynx.cc).

If you use a self-hosted server, the operator of that server is the Data Controller.

2. WHAT INFORMATION WE COLLECT

2.1 Information You Provide

When you create an account or use the Services, we collect:

Data Type	Purpose	Required
Email Address	Account identification, login, password recovery, service communications	Yes
Password	Authentication (stored as cryptographic hash, not plaintext)	Yes

We do NOT require or collect:

Full name
Phone number
Physical address
Date of birth
Payment information (the app is free)
Government ID numbers

2.2 Information Collected Automatically

When you use the Plynx Cloud Server, we automatically collect:

Data Type	Purpose	Stored
IP Address	Security, fraud prevention, abuse detection	Yes (registration IP and last login IP)
Last Login Timestamp	Account security, activity monitoring	Yes
Device Tokens	Hardware authentication	Yes
App Identifier	Distinguish between different client applications	Yes
Region	Server optimization (if applicable)	Yes

2.3 IoT Device Data

When your hardware devices connect to the Plynx platform, we may collect and store:

Data Type	Purpose	Stored
Authentication Tokens	Device authentication	Yes
Widget Data	Display values on dashboards (sensor readings, states, etc.)	Yes
Historical Data	Time-series data for graphs and charts (if you use SuperChart widgets)	Yes
Device Connection Status	Show online/offline status	Temporarily
Device Last IP	Security and debugging	Yes

2.4 Information Stored Locally on Your Device

The Plynx App stores certain information locally on your device using secure storage (Keychain on iOS):

Email address
Password (encrypted)
Server configuration (host, port)
Access tokens
Dashboard preferences

This data is stored locally and is not transmitted to us except as necessary to authenticate and use the Services.

2.5 Information We Do NOT Collect

We want to be clear about what we do NOT collect:

Location data (GPS)
Contacts
Photos or media files
Microphone or camera access
Advertising identifiers
Third-party analytics (no Firebase Analytics, Google Analytics, etc.)
Browsing history
Social media profiles

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 To Provide the Services

Create and manage your account
Authenticate your login
Connect your hardware devices
Display your dashboards and widget data
Store historical data for charts

3.2 To Maintain and Improve the Services

Monitor service performance
Debug technical issues
Improve user experience

3.3 To Communicate with You

Send password reset emails
Notify you of important service updates
Respond to your support requests

3.4 To Ensure Security

Detect and prevent fraud
Identify unauthorized access
Protect against abuse

3.5 To Comply with Legal Obligations

Respond to lawful requests from authorities
Comply with applicable laws and regulations

We do NOT use your information for:

Advertising or marketing
Selling to third parties
Profiling for commercial purposes
Automated decision-making that affects your rights

4. HOW WE STORE YOUR INFORMATION

4.1 Storage Location

If you use the Plynx Cloud Server (plynx.cc):

Your data is stored on servers that may be located in Europe or the United States
We use industry-standard security measures

If you use a self-hosted server:

Your data is stored on your own infrastructure
You are responsible for data security and compliance

4.2 Data Security Measures

We implement reasonable security measures, including:

Password hashing (not stored in plaintext)
Encrypted connections (TLS/SSL)
Access controls
Regular security reviews

5.1 We Do NOT Sell Your Data

We do NOT sell, rent, or trade your personal information to third parties for marketing or any other purpose.

We may share your information only in these limited circumstances:

Recipient	Purpose	Type of Data
Service Providers	Infrastructure hosting	Technical data
Legal Authorities	When required by law or legal process	As legally required
Successors	In case of merger, acquisition, or sale of assets	All data (with notice)

5.3 Aggregated Data

We may share aggregated, anonymized data that cannot identify you (e.g., total number of users, general usage statistics).

6. DATA RETENTION

6.1 Active Accounts

We retain your data for as long as your account is active or as needed to provide the Services.

6.2 Account Deletion

When you delete your account:

Your personal data (email, password hash) is deleted
Your dashboards and widget configurations are deleted
Historical data is deleted
Some anonymized logs may be retained for security purposes

6.3 Retention Periods

Data Type	Retention Period
Account data	Until account deletion
Historical/chart data	Until account deletion
Server logs	Up to 90 days
Backup data	Up to 30 days after deletion

7. YOUR RIGHTS AND CHOICES

You have the following rights regarding your personal data:

7.1 Access

You can request a copy of your personal data.

7.2 Correction

You can update or correct inaccurate data.

7.3 Deletion

You can delete your account and all associated data directly from the app:

Open the app and go to Settings
Tap Delete Account
Enter your password to confirm
Your account will be immediately deleted

What gets deleted:

Your user profile and email
All dashboards and widget configurations
All device tokens and authentication data
All historical data (SuperChart, reports)
Push notification tokens

Important: After deletion, your data is moved to a secure backup location and retained for 5 days for administrative recovery purposes (e.g., in case of accidental deletion or account compromise). After 5 days, all data is permanently and irreversibly deleted.

You can also request deletion by contacting us at: niccolo.pagano@studbocconi.it

7.4 Data Portability

You can request your data in a portable format (JSON export).

7.5 Restriction

You can request that we limit how we use your data.

7.6 Objection

You can object to certain processing of your data.

Where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, contact us at: niccolo.pagano@studbocconi.it

We will respond to your request within 30 days (or as required by applicable law).

8. DATA SECURITY

We implement reasonable administrative, technical, and physical security measures to protect your information, including:

Cryptographic hashing of passwords
Encrypted data transmission (TLS)
Secure authentication mechanisms
Regular security assessments

However, no system is completely secure. We cannot guarantee absolute security of your data. You are responsible for:

Keeping your password confidential
Securing your devices and tokens
Reporting any security incidents

9. INTERNATIONAL DATA TRANSFERS

If you access the Services from outside the country where our servers are located, your data may be transferred internationally.

9.1 For EU Users

The Plynx Cloud Server (plynx.cc) is located in Europe. Your data remains within the European Economic Area (EEA).

If we transfer data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs)
Adequacy decisions by the European Commission
Your explicit consent

9.2 For Non-EU Users

If you access the Services from outside the European Union, your data is transferred to and stored on our servers in Europe.

10. CHILDREN’S PRIVACY

The Services are not intended for children under 16 years of age (or the applicable age of digital consent in your jurisdiction).

We do not knowingly collect personal information from children. If we discover that we have collected data from a child, we will delete it promptly.

If you believe we have inadvertently collected data from a child, please contact us immediately at niccolo.pagano@studbocconi.it.

11. THIRD-PARTY LINKS AND SERVICES

The Services may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties.

We recommend reviewing the privacy policies of any third-party services you use.

12. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

12.1 Right to Know

You can request information about:

Categories of personal information collected
Purposes for collecting the information
Categories of third parties with whom we share information

12.2 Right to Delete

You can request deletion of your personal information.

12.3 Right to Opt-Out

You can opt out of the “sale” of personal information. However, we do NOT sell your personal information.

12.4 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights.

12.5 Categories of Personal Information Collected

Category	Collected	Sold	Business Purpose
Identifiers (email)	Yes	No	Account management
Internet activity (IP, tokens)	Yes	No	Service provision, security
Geolocation (IP-based only)	Yes	No	Security
Inferences	No	No	N/A

To exercise your CCPA rights:
Email: niccolo.pagano@studbocconi.it
Subject: “CCPA Request”

We will verify your identity before processing your request.

If you are a resident of the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

13.1 Legal Bases for Processing

We process your data based on:

Legal Basis	Processing Activity
Contract	Account creation, service provision
Legitimate Interest	Security, fraud prevention, service improvement
Legal Obligation	Compliance with laws
Consent	Where specifically requested

Access (Art. 15) - Request a copy of your data
Rectification (Art. 16) - Correct inaccurate data
Erasure (Art. 17) - Request deletion (“right to be forgotten”)
Restriction (Art. 18) - Limit processing
Portability (Art. 20) - Receive data in portable format
Object (Art. 21) - Object to processing based on legitimate interest
Withdraw Consent (Art. 7) - Withdraw consent at any time

13.3 Data Controller

Data Controller:
Niccolo Pagano
Email: niccolo.pagano@studbocconi.it

13.4 Supervisory Authority

You have the right to lodge a complaint with your local data protection authority.

For Italy: Garante per la protezione dei dati personali
Website: https://www.garanteprivacy.it

13.5 Data Protection Impact Assessment

Given the limited nature of data we collect and the absence of high-risk processing activities, a formal DPIA is not required. However, we regularly assess our data practices.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do:

We will update the “Last updated” date at the top
For material changes, we will notify you via:
- Email to your registered address
- Notice in the App

Your continued use of the Services after changes become effective constitutes acceptance of the updated Policy.

15. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us: